USCIS issued a policy memo implementing the decision in Williams v. DHS Secretary for all spousal immediate relative visa petitions under INA §204(l) after the death of a U.S. citizen petitioner. USCIS stated that it will follow the Williams decision for all cases, including those arising outside the jurisdiction of the Eleventh Circuit. This memo partially supersedes the December 16, 2010, PM-602-0017, Approval of Petitions and Applications After the Death of the Qualifying Relative Under New Section 204(l) of the INA.
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